Protection of Personal Information

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  2. Protection of Personal Information

Privacy Policy

JAFCO Group Co., Ltd. ("the Company") ensures proper protection of personal information (in accordance with the provisions of Article 2 (1) of the Act on the Protection of Personal Information), and that every executive and employee takes responsibility for adequate information management and this policy is effectively implemented in order to meet the trust of our shareholders, fund investors, portfolio companies, and others.

  1. In pursuit of "value creation through private equity", the Company shall use personal information in the cases of fund establishment, investment, value adding to portfolio companies, and investment liquidation, for the purposes of use listed below:
    1. Establishment, management and related operations of funds, etc.
      • To introduce funds, etc. and related services
      • To conduct affairs related to the establishment and management of funds, etc.
      • To confirm that the customer is the person himself/herself or the agent of himself/herself
      • To report to customers the management results of funds, etc.
      • To carry out research and development of funds, etc. through market survey, data analysis, questionnaires, etc.
    2. Private equity investment and related operations
      • To identify investment candidates
      • To prepare a capital/ financial policy for investment candidates
      • To decide whether to invest in an investment candidate based on examination and evaluation of its business potential, technology, products, etc.
      • To exercise rights and fulfill obligations based on laws, contracts, etc. and carry out other clerical work related to investment.
    3. To introduce and offer services provided by the Company, the Company's subsidiaries and affiliates and outside supporting companies, and to carry out related clerical work with the aim of adding value to portfolio companies (including consulting)
    4. To sell securities holdings, etc. and carry out related clerical work
    5. If the processing of all or part of the personal information has been outsourced by other business operators, to appropriately carry out such outsourced operations
    6. Other than above, to perform transactions with customers appropriately and smoothly
    7. To procure products, services, funds, etc. necessary for the operation of the Company and the Company's subsidiaries and affiliates
  2. The Company has appointed an information management officer, who takes charge of information management for the Company as a whole, and an information manager at each division to clarify the responsibility and authority regarding security control measures for personal information, and build a system of reporting to the officer/managers in case a leak or similar incident of personal information was confirmed or suspected.
  3. To ensure effective implementation of this policy, the Company shall educate all of its executives and employees to comply with laws and regulations with regard to protecting customers' and other personal information. The Company shall establish internal rules and other compliance programs related to personal information protection, and implement, maintain and continue to improve these programs to ensure thorough understanding of its importance among its executives, employees and related parties. The Company shall also inspect and audit the implementation status of such compliance programs.
  4. The Company shall appropriately control access to personal information and related computer systems and take appropriate information security measures against unauthorized accesses, computer viruses, etc., to prevent loss, damage, alteration, and/or leakage of personal information.
  5. Except for cases permitted by laws and regulations or when the customer's consent is obtained in advance, the Company does not provide personal information obtained from its customers, etc. to third parties. However, the Company will jointly use personal information with others within the scope provided below:
    1. Items of personal data shared
      • Basic information including name, address, phone number, e-mail address, etc., and investment-related information including the number of shares held, etc.
    2. Scope of persons that share the information
      • Subsidiaries and affiliates that are listed in the Company's Annual Securities Report
      • Companies that list the Company as a subsidiary or an affiliate in their Annual Securities Reports, and such companies' subsidiaries and affiliates listed in their Annual Securities Reports
      • Outside supporting companies, including securities firms and stock transfer agents, that jointly provide IPO preparation and value adding support for investee companies
    3. Purposes of joint use of personal information
      • Same as in 01.
    4. Persons with responsibility for joint use of personal information

      JAFCO Group Co., Ltd.
       Address: 1-23-1 Toranomon, Minato-ku, Tokyo
       Representative: President & CEO Keisuke Miyoshi

  6. When outsourcing the handling of personal information to third parties, the Company conducts impartial investigations of such parties and supervises such parties to ensure that appropriate measures are taken to protect personal information and confidentiality.
  7. If the Company receives a request from a customer, etc. for disclosure, amendment, etc. of personal information provided by the customer, the Company will promptly respond to the request to a reasonable extent possible. If you have any opinions or questions regarding the Company's handling of personal information, please call 81-50-3734-2025 or email info@jafco.co.jp.

    The Company is a member of the following Accredited Personal Information Protection Organization:
    [Name and Contact]
    The Japan Investment Advisers Association
    Complaints and consultation: 81-3-3663-0505

  8. With regard to the handling of information related to the Company's executives and employees, the Company shall manage in accordance with its internal rules, etc. separately established.
  9. JAFCO Group Co., Ltd.
    1-23-1 Toranomon, Minato-ku, Tokyo
    President & CEO Keisuke Miyoshi